After an argument with his wife, Russell Pelo left home, checked into a motel, telephoned his wife with threats of self-harm, and bought a shotgun. Police brought him to Ellsworth Municipal Hospital. A magistrate found probable cause to believe that Pelo was seriously mentally impaired and likely to injure himself, and ordered his emergency detention in the hospital’s psychiatric unit for examination and care.
Pelo initially refused to sign the hospital admission form authorizing release of information to his insurer and acknowledging responsibility for charges not covered by insurance. He later signed, but claimed he did so under duress after a nurse said the hospital could not ensure the safety or return of his belongings without his signature. He remained hospitalized from January 8 through January 13, 1995. Although a hospitalization referee found that Pelo had bipolar disorder and would benefit from treatment, the referee concluded that the statutory grounds for further involuntary hospitalization had not been proved and released him.
The hospital charged $2,775.79 for its services and assigned the account to Credit Bureau Enterprises for collection. In small claims court, Pelo admitted the hospitalization but denied agreeing to pay. The district associate judge held that Cerro Gordo County was not statutorily responsible because Ellsworth was a private rather than a state hospital, dismissed the claim against the county, and entered judgment against Pelo. On appeal, the district court judge affirmed, concluding both that Pelo’s signed form was an enforceable contract and, alternatively, that he was liable under quasi-contract. The Iowa Supreme Court granted discretionary review.